Illinois Appellate Court
Criminal Court
Confrontation
Admission of domestic battery victim's prior inconsistent written statement about incident, which was made shortly after incident, did not violate confrontation clause. Victim (who was Defendant's sister) acknowledged on direct examination that she wrote and signed statement but could not recall what happened during incident as she was on Darvocet and blacked out and had been drinking for a month straight. Victim was available at trial and was subject to cross-examination, when she testified that she could not recall making the written statement.